Summary On the afternoon of 05 December 2006, the barque PictonCastle departed Lunenburg, Nova Scotia, bound for St. George's, Grenada, in the eastern Caribbean Sea. On board were 12crew and 16other persons who had signed on as trainees. On the evening of December8, shortly before 2235, while in heavy weather, a deckhand was swept overboard from the leeward side of the vessel. An air and sea search ensued, but it was unsuccessful. Ce rapport est galement disponible en franais. Other Factual Information Built in England in 1928 as a riveted steel-hulled side trawler, the PictonCastle was rebuilt in 1955as a freighter. From 1996 to 1997, the vessel was refitted in Lunenburg, Nova Scotia (its operating base), as an ocean-going three-masted barque-rigged sail training vessel (see Photo1). The decks are oiled pine wood. The hull is subdivided by five transverse watertight bulkheads, with watertight doors providing access to the main compartments. PictonCastle (courtesy D. Moreland) Twenty berths are located in the forecastle, eight of which are in the lower forepeak. The former hold has been divided to provide an eighteen-berth 'tween deck accommodation and main salon in the forward section, and a stowage hold in the after section. The engine room is located aft of the stowage hold. The master and mate cabins and a small mess room are located aft and below the quarterdeck. Below this area, there are two double cabins and a compartment for eight berths. According to the company's Web site, the vessel has berths for 40sail trainees and 12professional crew members. The galley is located forward on the main deck and above the main salon. The charthouse, containing the navigational equipment, is located on the forward end of the quarterdeck (see Figure1). A door at the after end of the charthouse provides access to the ship's office. The engine controls are located forward of the charthouse. The ship's magnetic compass and wheel are located at the after end of the quarterdeck. A set of davits are fitted on each side of the quarterdeck. An open skiff with an outboard engine was stowed in the starboard davits. A monomoy,3 the keel of which was about level with the quarterdeck, was stowed in the port davits. Preparations for Departure The PictonCastle returned to Canada from its fourth world circumnavigation voyage on 14June2006. The vessel later departed Lunenburg, at the end of June, to participate in a number of tall ship festivals, including a voyage to the Great Lakes. The vessel later returned to Lunenburg, and preparations were subsequently made for a winter voyage in the Caribbean. The voyage was to include the signing on and off of crew and trainees at various ports, as well as the vessel being refurbished for use in the television production of PirateMaster. On November 21, the senior master, who was also the vessel company's managing director, handed over command of the vessel to the master. The senior master had been the vessel's only master since1997, after the vessel was refitted as a sail training vessel. This voyage was to be the new master's first as master on the PictonCastle. He had previously sailed as chief officer on the vessel for 13months during 2001-2002. It was also to be the chief mate's first voyage on board. Because there was a lack of available documentation, he had to rely on verbal briefings and meetings to become fully familiar with the vessel's policies and procedures. The deckhand4 arrived on board the vessel on November26. This would be the deckhand's second voyage on board this vessel - she had previously sailed on the vessel for five months in2006. Most of the crew members and trainees5 had joined the vessel around November26, with familiarization tours conducted as each arrived on board. Some trainees were given a familiarization tour by the deckhand. In preparation for the voyage, the crew, including the deckhand and trainees, participated in various drills, training sessions, and workshops including going aloft, sail-setting, bracing, and boat handling. A fire drill, during which hoses were charged, was conducted. Information sessions were held for the general alarm, muster stations, abandonment, and man overboard; however, no drills were conducted. Immersion suits were available but were not tried on before departure. On November 27, the crew and trainees signed the articles of engagement for the vessel. A "four hours on, eight hours off" watch system was to be established for the voyage. However, the departure of the second officer (2/O) on November30, two days before the planned date of departure, resulted in changing to a "six hours on, six hours off" watch system for the deck officers. The master, bosun, and a crew member, who was to be the acting 2/O, were to work the 0600-1200 and 1800-2400 watches. The chief officer was to work the 1200-1800 and 2400-0600 watches. The remaining crew members and trainees were divided into groups and assigned to work one of the three "four hours on, eight hours off" watches. The deckhand, who had signed on the vessel as a volunteer deckhand,6 was subsequently given the role and responsibility of a lead deckhand for a watch. As a lead deckhand, she was paired with another crew member- the purser, who does not normally stand a watch but who does perform day work- and assigned five trainees to work the 0800-1200 and 2000-2400 watches. Due to adverse weather, the planned December2 departure was postponed. The forecasts for December5 and 6showed two high-pressure systems filling in behind the low-pressure system, providing favourable winds for sailing south. The ship's office was unable to hire a cook by the time of departure, and it was decided that crew members and trainees would be assigned galley duty on a rotational basis. History of the Voyage At about 1315 Atlantic standard time,7 on December5, the PictonCastle departed Lunenburg bound for St.George's, Grenada, which is located at the southern extremity of the Windward Islands in the eastern Caribbean Sea. The weather was overcast with a moderate breeze. The departure was uneventful as the vessel proceeded on a southeasterly course under sail. Ship checks8 were performed hourly. On the evenings of December5 and7, in accordance with the master's night orders, the watch reviewed the man-overboard procedures. A cold front was expected with a major shift of winds. At 2100 on December7, the winds recorded in the log book were Beaufort force6.9 Earlier that day, the crew had been preparing the vessel for heavy weather. Watertight doors and hatches were closed. Items secured before departure were checked to make sure that they were securely stowed and, where necessary, their lashings reinforced. Static safety lines, to assist the crew in moving about on deck, had been rigged midship; these were set up between the galley and the stairs leading up to the quarterdeck, as well as along the starboard side of the quarterdeck between the charthouse and the taffrail. At 2135, the fore-topmast staysail was struck because it had a large rip in the leech. At 2330, the vessel was hove to under the starboard clews of the lower topsails, waiting for the passing of the cold front. At 2400, the winds were recorded as Beaufort force8.10 The deckhand continued to assist other crew members throughout the day and after the end of her watch at midnight, to until about 0400, when she retired to her bunk. At 0400, on December8, the winds were recorded as Beaufort force10.11 Ship checks were being carried out hourly, and the vessel was rolling heavily in a beam swell. During the 0000-0400 watch, with the vessel rolling heavily, members of the deck watch spent most of their time sitting in two groups on the port and starboard sides of the quarterdeck. Toward the end of the watch, the master arrived on the quarterdeck with a bottle of rum and gave a shot to each member of the deck watch including trainees. Because of the severity of the weather, the 0400-0800 watch decided that all persons on deck were to be paired up, and that they were to remain on the windward side of the vessel. At 0600, the deckhand got up for galley duty. At about 0930, and after the front had passed, the main engine was brought on line. The master decided to proceed south to seek more favourable sea conditions. The winds at that time were recorded in the log book as Beaufort force9.12 The heavy weather conditions continued throughout that day. The deckhand remained up and about during most of the day, helping to carry out regular duties such as assisting in the galley and securing and lashing items that might move about in heavy weather. At approximately 1500, the deckhand requested assistance from the purser to secure fuel and water containers that had come loose in the port breezeway. While they were re-lashing the containers, seawater was being shipped up to their knees. At about 1815, the assistant engineer exited the engine room to check the main engine overboard discharge along the port side. However, she was prevented from doing so by the large volume of shipped seas flowing aft in the port breezeway. The chief engineer later decided that, in lieu of going into the breezeway to check the discharge, he and the assistant engineer would keep a close eye on the engine temperatures. By 2000, the winds were northwesterly at Beaufort force9. Helm orders at the time were to keep the wind between the starboard quarter and stern. The engine was full ahead, and the vessel's speed was 9knots. It was reported that trainees were to be accompanied by crew members and that no one was to be alone on deck. The trainees had been previously told that, if they felt uncomfortable being out on deck, they did not have to stand their watch and could remain below deck. By this time, most of the trainees were either too uncomfortable to be on deck or too seasick to report for their watch. By 2100, the deckhand and a trainee had reported for their watch on the quarterdeck. The deckhand, however, expressed concern to the acting 2/Oabout her ability to handle the helm in the existing sea conditions. In addressing her concern, one of the two crew members due for relief then volunteered to take the deckhand's place at the helm. It was decided that this crew member and the acting 2/Owould each take 30-minute turns at the helm. At this point, and after consulting with the master, the acting 2/Osent the deckhand below to get some rest. The deckhand was also told by the acting 2/Oto begin ship checks in an hour's time. The other crew member from the previous watch was relieved and, after completing his ship check, went to the forecastle where he saw the deckhand discussing how to both carry out ship checks and get rest in between with a crew member. At some time after 2100, but before 2200, as the master and a crew member were busy in the port breezeway attending to a fuel spill and re-lashing items that had again come loose, the vessel shipped a large amount of water on deck. This caused the master to lose his footing and fall. He subsequently instructed the watch that the port breezeway was off limits. At about 2200, the master, surprised at seeing the deckhand on the quarterdeck, ordered her to go below to get some rest. The master later went below to his cabin to change into dry clothing. At about 2230, both the crew member who had been taking turns at the helm since the previous watch and the trainee were relieved of their duties. They proceeded to go below deck to sleep. On the way, the crew member met the deckhand, who informed him that she was doing a ship check. The deckhand was wearing light clothing and a raincoat. Shortly before 2235, the vessel heeled to port and a large wave struck the port side, lifting the monomoy in the port davits and flooding the port breezeway. The two crew members at the helm station immediately heard screams from port side aft. One of them briefly saw someone in the water astern of the vessel. The alarm was raised by yelling "man overboard," and the acting 2/Owent forward to alert the crew. At this time, seas were estimated at 5to 6m. Search and Rescue Operations The crew members who were on the quarterdeck at the time of the person going overboard deployed the port-side man-overboard marker pole, with life ring and light. The starboard marker pole with a life ring and light was released, but the wind blew it onto the deck below, where it became entangled in the stern chocks before being freed and deployed. The crew was unable to maintain visual contact with the person who had fallen overboard. A crew member called out bearings and distances to the lighted marker poles and, although the poles were initially kept in sight, it became increasingly difficult to maintain visual contact due to the weather and sea conditions. Additional life rings fitted with lights, immersion suits, and lifejackets were also thrown overboard to help mark the area and provide the person in the water with items to remain afloat. The master, who had been changing into dry clothes in his cabin, ran to the charthouse and pushed the man-overboard button on the global position system (GPS) at 2235, marking the occurrence position. This was entered in the log as 3847.0'N, 06033.5'W. The vessel was approximately 376nautical miles (nm) south-southeast of Lunenburg (see AppendixA). As other crew members and trainees began to arrive on the quarterdeck, additional lookouts were posted. The gripes were loosened and preparations were being made to launch the starboard skiff, but it was decided that it would be too dangerous to do so in the prevailing sea conditions. The skiff eventually broke free from its davits and was swept overboard. It was recovered two days later. Approximately 30minutes after the alarm was raised, the vessel had manoeuvred back to within reach of one of the deployed life rings, which was found empty. Other deployed safety equipment was located and retrieved later during the search. The crew was unable to send an alerting message via the single side band radio, even with the help of the instruction manual. At about 2320, MAYDAY broadcasts were made using the frequencies listed for the Canadian and United States coast guards, but there was no response. MAYDAY broadcasts were also made using very high frequency (VHF) radios in case a vessel was nearby, but there was no reply. Contact was eventually made at 2335with the senior master in Lunenburg by satellite telephone. Having been informed of the occurrence, the senior master called 911and, at 2338, was connected with the Joint Rescue Coordination Centre (JRCC) in Halifax, Nova Scotia. The vessel's position in the JRCC incident log was reported as 3842.2'N, 06631.4'W. The Rescue Coordination Center (RCC) in Norfolk, Virginia, United States, was then contacted and given the necessary information, because the occurrence area was in its area of responsibility. Several headcounts had been taken, and at about 2340, the identity of the missing deckhand was confirmed. At about midnight, the trainees were sent below deck for their safety. At 2352, the Canadian Mission Control Centre (CMCC) at Trenton, Ontario, informed JRCC Halifax that it had received a 406MHz signal from the PictonCastle's emergency position indicating radio beacon (EPIRB). The signal position was 3840'N, 06030'W. At 0010, the senior master was contacted and he confirmed that the vessel's last known position- now two hours old- was 3842.2'N, 06031.4'W. The vessel's international maritime satellite communication system (INMARSAT-C) had also been used to broadcast a distress alert at 0026, which was received by RCC Norfolk, and the Maritime Rescue Co-ordination Centre (MRCC) in Falmouth, United Kingdom.13 By 0040, JRCC Halifax was informed that RCC Norfolk had made contact (by satellite telephone) with the vessel. A Canadian search and rescue (SAR) C130Hercules aircraft arrived on scene at 0350. It was determined by SAR authorities that the PictonCastle's EPIRB had been activated but that it had not been deployed, and so the vessel was instructed to turn it off.14 The Hercules deployed a self-locating datum marker buoy within the area of the safety equipment deployed by the PictonCastle, and commenced an expanding square search. The PictonCastle continued searching through the night. Drift calculations and search patterns were established and the crew used handheld searchlights to try to locate the deckhand. However, some of the searchlights maintained their charge for only a short time and required frequent recharging. Electrical extension cables were then brought up on deck to ensure the continuous operation of at least two searchlights. Most of the vessel's crew remained on deck, assisting with the search through the night and the following morning, by which time some had been awake for about 30hours. Some crew members also sustained minor injuries, including one who fell while in the engine room, striking his head. No structural damage to the vessel was reported; however, there was some minor damage to sails, rigging, and the skiff, which broke free from its davits. On four occasions during the early morning hours, some crew members reported hearing someone shouting from somewhere off the ship, but no one was seen or found. In all, two Canadian and two United States SAR aircraft, as well as at least four commercial vessels, participated in the search, which lasted for three days before it was suspended on the evening of December11. The PictonCastle, which had established a temporary "short" watch schedule for the officers and crew that allowed periods of rest, continued its search of the area until the following day. The deckhand was not recovered and is presumed drowned. On December 24, the PictonCastle arrived at the island of St.Kitts where an investigator who was appointed by the Ministry of Transport for the Cook Islands joined the vessel to begin an investigation into the occurrence. Weather Conditions At 1830 on December 8, the United States National Weather Service's high seas forecast issued the following: hurricane-force wind warning with winds of 50to 65knots and seas of 17to 27feet from 38N to 44N within 180nm east of a front extending from 48N, 53W to 37N, 60W to 31N, 64W; gale warning with winds 25to 35knots and seas 12to 21feet... from 31N to 44N west of 60W, except where noted above. The weather, as recorded in the vessel's log book for 2300 on December8, indicated northwest winds of force9 on the Beaufort scale, poor visibility, and squalls. The marine weather forecasts were found to be valid. Vessel Certification The vessel was certified by the Cook Islands Ship Registry as a sail training vessel on 02July2004. The vessel was permitted to carry a complement of 52officers and trainees in worldwide training, with provision for 60guests to be carried on special limited water excursions, based on safety equipment, lifesaving capabilities, and bunk space. The vessel's minimum safe manning certificate was issued by the Registrar of Ships, Cook Islands, on 15March2006. The certificate required a minimum of nine officers and ratings as follows: one master, one chief officer, two radiotelephone operators, four lead seamen, and one engineering officer. The vessel's safety certificate was valid until 01June2007. A certificate of authority, approved training program, was issued by the Registrar of Ships, Cook Islands, on 19September2003. This certifies that the vessel's training manual"... has been suggested and recognized by this authority as a training handbook for the subject vessel." Personnel Qualifications, Training and Experience The master held a certificate of competency as master, without limitation, issued by the Federal Republic of Germany in2004. The certificate was endorsed by the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers,1978, as amended in 1995(STCW Convention), but it was not endorsed by the Cook Islands. Additionally, the master held an ocean-going yacht certificate with no limitations for motor and sail-equipped yachts. The master was issued a limited master's licence for a gross tonnage of up to 8000in 1995,and an unlimited master's licence in1997. The master's experience included command on a variety of sailing vessels. He had served in various positions on board sailing vessels since1979. This was the master's first voyage in command of the PictonCastle. The chief officer was issued a certificate as chief mate by the Government of the United Kingdom of Great Britain and Northern Ireland on 17June2005. The certificate was STCW Convention- endorsed with no area limitations for vessels with a gross tonnage of less than3000, but it was not endorsed by the Cook Islands. He began his training for deck at sea in1999. In2004, he underwent training and served as 2/Oaboard a square-rigged sailing vessel. This was the first officer's first voyage on the Picton Castle. The acting 2/O was issued, but did not have in her possession on the day of sailing, a licence by the United States Coast Guard on 28November2006 to serve as a master of a steam, motor, or auxiliary sailing vessel of not more than 100gross registered tons, and as a mate of a vessel of not more than 150gross registered tons, upon near coastal waters. The acting 2/Ofirst began sailing in2001, and had sailed on a number of sailing vessels. This was the acting 2/O'sfirst voyage on the Picton Castle. The deckhand first joined the PictonCastle in March2006 as a trainee- a position she held for three months before becoming a deckhand for another two months. She had sailed on other sail training vessels including the Concordia and Niagara. At the time of the occurrence, she had received no formal training in marine-related emergencies and held no certificates of competency, nor was she required to. Of the remaining eight crew members, four were making their first voyage on the PictonCastle. Five of the eight had received formal training in emergency procedures, and the use of lifesaving or firefighting equipment. Table1 provides a summary of the certification and experience of the crew members. Other than the master and the chief officer, none of the crew held a Global Maritime Distress and Safety System (GMDSS) general operator's certificate, nor was this required in the minimum safe manning certificate. Furthermore, because the vessel was not subject to the International Convention for the Safety of Life at Sea (SOLAS Convention), the crew was not required to comply with the GMDSS requirements. Summary of the certification and experience of the master, officers, and crew of the PictonCastle Overall, the experience of the 16 trainees was limited to small recreational sailing vessels in confined or sheltered waters. Most trainees had never been on board a vessel as large as the PictonCastle and had previously not been to sea. One of the trainees, who was a registered nurse and the vessel's medical officer, had previous sailing experience. Policies and Procedures The policies and procedures for the PictonCastle are contained in the Handbook for Crew. This document was prepared to orient new crew members to the vessel and to provide information on the vessel's operation, including the following: general orders, orders when underway, and officers' orders in-port policies and procedures crew duties workshops crew skills Furthermore, policies and procedures and records were in place, including the following: engine room operating procedures and maintenance records deck and rig maintenance records garbage policy Sail Trainee Programs For many sail training vessels, trainee programs are undertaken for the purpose of character building and education through participation. The operator of the PictonCastle advertises a training program that offers paying trainees the opportunity to learn traditional square-rigged sailing as a full member of the crew. Trainees are taught a number of skills, including sail making, rigging, and navigation, through the use of information sessions and workshops. There was no training syllabus or formal assessment process, nor was the training program intended to provide instruction to obtain certificates of proficiency. Crew Familiarization and Safety Training Drills Upon joining the PictonCastle, new crew members and trainees were given a familiarization tour by an officer or another crew member. The tours varied but, for the most part, they covered the layout of the vessel. Days in advance of boarding the vessel, each new crew member was mailed a copy of the Handbook for Crew. It informs the reader that firefighting, man-overboard and abandon-ship drills are to be performed regularly. Emergency information was provided in the station bills (muster lists), and emergency procedures were posted in different parts of the vessel. The station bills addressed general quarters, fire and damage control, abandon-ship, and man-overboard situations. The station bills were revised according to the complement on board at the time. A copy of the station bill posted at the time of the occurrence was not available because it had been subsequently revised. The emergency procedures described signals to be used for any emergency on board, including damage control. However, a subsequently revised station bill did not contain information concerning damage control. Liferaft assignments had been posted in different parts of the vessel on a separate sheet at the time of the occurrence. A subsequently revised list divided the officers, crew members, and trainees among the various survival craft. Use of Safety Harnesses The wearing and use of safety harnesses on deck when underway at night or during heavy weather is a standard operating procedure on many vessels, including most sail training vessels. As an example of safety harness best practice, Transport Canada publication TP13313E, Standard Relating to Design, Construction and Operational Safety of Sail Training Vessels,15 recommends that safety harnesses be attached to lifelines of sufficient length to extend fore and aft along the weather deck on each side along the normal working area. Fastening points for the attachment of safety harnesses should be provided close to the companionway and on both sides of the control station. Efficient means of securing the lifelines of safety harnesses should also be provided on exposed decks. Chest harnesses are acceptable for work on deck, but when going aloft, an approved full-body fall-arrest harness should be worn and the wearer should be trained in its use. In this occurrence, crew members and trainees neither wore nor used safety harnesses when working on deck at night or during heavy weather. There were no established fastening points to which safety harnesses could be attached. The crew and trainees used their hands to hold onto the safety lines rigged along the main deck and quarterdeck. The Handbook for Crew for the crew of the PictonCastle states that the use of a harness is optional except when directed. Although there is information that harnesses had not always been worn aloft, it was reported that it was the practice to wear and use a safety harness when going aloft on this voyage. The harnesses that were provided were of the belt type with a short lanyard, which confines the force of the fall to the area around the waist. Full-body harnesses are intended for use as body supports in work situations that involve the risk of falling, and consist of connected straps designed to distribute the force resulting from a fall over at least the thigh, shoulders, and pelvis. Some of the crew had brought their own harness. Regulatory Requirements The PictonCastle was under Cook Islands registry and was therefore subject to Cook Islands requirements. Part Vof the Cook Islands' Shipping Act,1998 deals with safety and is modeled after several international conventions, including the SOLAS Convention of 1974and the SOLAS Protocol of 1978.16 However, the PictonCastle, as a sail training vessel with a gross tonnage of284, was subject to few SOLAS Convention regulations. No regulations had been adopted by the Cook Islands for the safety of vessels and crew not subject to the international conventions. However, at the time of the occurrence, regulations were being developed17 to address safety issues pertaining to Cook Islands-registered sailing ships engaged in sail training and maritime education activities at sea under sail. Vessel Inspections As a vessel registered in the Cook Islands, the PictonCastle is subject to annual inspections by Cook Islands flag surveyors. On 21March2006, the vessel underwent a safety survey while in Cape Town, South Africa. No deficiencies were noted in the survey report. Transport Canada Inspections Port state control (PSC) is a ship inspection program where a foreign vessel entering another state's waters is boarded by authorized inspectors of that state (that is, the port state) to verify the vessel's compliance with the international maritime conventions adopted by its flag state. Transport Canada decides which foreign ships to inspect based on a combination of risk analysis and random selection. As a foreign vessel in Canadian waters, the PictonCastle was potentially subject to PSCinspections by Transport Canada. Transport Canada had not conducted any PSCinspections on the PictonCastle. As a foreign vessel, the PictonCastle is not permitted to operate between Canadian ports unless granted a coasting licence issued under the Coasting Trade Act by the Minister of National Revenue (in effect the Canada Border Services Agency). The primary intent of the legislation is to protect the interests of the operators of Canadian vessels, while allowing a foreign vessel to access the coasting trade if a suitable Canadian vessel is not available (this determination is made by the Canadian Transportation Agency). Issuance of a coasting licence is subject to the payment of the applicable duty (if any) and a ship safety inspection by Transport Canada. In July2004, a coasting licence was issued to the operator of the PictonCastle, permitting it to use the vessel to participate in the Tall Ships 2004event. Transport Canada inspected the PictonCastle and issued a letter of compliance for coasting trade licence (Ship Inspection Certificate [SIC]10). The SIC10 was valid for one month and certified that the certificates and documents relating to the vessel were valid, and that appropriate lifesaving equipment was carried on board. There was no information to indicate that the vessel had applied for a coasting trade licence and was inspected before visiting Canadian ports during the summer of2006. In the absence of a valid coasting trade licence, the permissible length of stay for a foreign, non-duty-paid vessel in Canada is 30days from the inward clearance. If the vessel needs repairs, however, the local Canada Border Services Agency office has the discretion to permit a longer stay. The PictonCastle is regularly granted extensions for the duration of its stay at its operating base in Lunenburg while it undergoes maintenance or repairs between planned international voyages. Any work undertaken would be subject to inspection by the Cook Islands. Industry Standards for Sail Training Vessels Sail training has grown over the years, with dedicated organizations/programs in over 20countries. Many of these vessels are owned and operated by charities, foundations, and schools. The unique issues associated with sail training vessels have been recognized by sail training associations and organizations in Canada, the United Kingdom, the United States, and other countries. For example, the Canadian Sail Training Association provided input in the development of TP13313E. This voluntary standard was developed to address safety issues pertaining to Canadian mono-hulled sailing vessels engaged in sail training activities at sea. In the United States, the American Sail Training Association, of which the PictonCastle is a member, participated in the establishment of the Sailing School Vessel Act of 1982, which governed the standards and regulations for sail training vessels. The United States Coast Guard Marine Safety Manual, VolumeIII, Marine Industry Personnel, provides information and program interpretations on statutory and regulatory issues relating to the manning of sailing school vessels operated by the United States Merchant Marine Academy and State Maritime Academy. In addition to taking into consideration the vessel's route and specific characteristics, vessels equipped with one or more masts must carry a seaman (able seaman or deckhand as appropriate) for each mast and an additional able seaman for each square-rigged mast. For vessels with a gross tonnage of 100or more on ocean voyages, the three-watch standard is to be used, and at least 65percent of the deck crew must be able seamen.18 The Racing & Sailing Rules and Special Regulations, 2008Edition, of Sail Training International, a United Kingdom-based charity with worldwide membership that promotes the development and education of young people through the sail training experience, contains details for the participation of vessels in events organized by the charity. For example, the special regulations state that clipping points for safety harnesses are to be provided adjacent to workstations such as the helm, sheet winches, and masts.19 Vessels such as the PictonCastle are to provide such arrangements as are compatible with their standard operating procedures for those working on the weather decks. The special regulations also strongly recommend that at least 50percent of the permanent crew, including the captain/master, should have undertaken approved training in safety and survival within the five years before the start of an event organized by Sail Training International, which is to include practical, hands-on sessions.20